KVKK / GDPR Privacy Notice – TruOpt.ai

Last Updated: January 2026

This Privacy Notice has been prepared by ThumbsAd – Deniz Tekbaş (“Data Controller”) in accordance with the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the EU General Data Protection Regulation (“GDPR”) to inform you about the processing of your personal data on ThumbsAd.com and TruOpt.ai platforms.

1. Personal Data We Process

The following categories of personal data may be processed:

• Identity and contact information (name, surname, email, phone number)
• Account, subscription and billing information
• Payment and invoice data (processed via Paddle)
• IP address, logs and transaction records
• Device, browser and traffic data
• Advertising, campaign and platform usage data

2. Purposes of Processing

Your personal data are processed for:

• Providing access to TruOpt.ai platform and services
• Managing subscriptions, billing and customer relationships
• Operating AI automation and optimization services
• Fulfilling legal obligations
• Ensuring system security and audit logs
• Improving products and services
• Sending marketing communications (with explicit consent)

3. Legal Bases

Personal data are processed based on:

• Performance of a contract
• Legal obligations
• Explicit consent
• Legitimate interests of the Data Controller

4. Transfer of Personal Data

Your personal data may be transferred to:

• Paddle (payment and billing services)
• Cloud hosting and infrastructure providers
• Email, CRM and customer support providers
• Authorized public institutions and authorities

Your data may be transferred abroad in accordance with GDPR and KVKK.

5. Your Rights

Under KVKK Article 11 and GDPR Articles 12–22, you have the right to:

• Learn whether your data are processed
• Request access to your data
• Request correction, deletion or restriction
• Object to automated decision-making
• Request compensation for damages

6. Exercising Your Rights

You may submit your requests by:
Email: info@thumbsad.com
or in writing to the address below.